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Complaint
1. Ansheline Mae A. Bacudio
JD-4th
year
REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
___ Judicial Region
Regional Trial Court
Branch ________
Pasay City, Metro Manila
NATSHA QUINTO
Petitioner,
-versus-
CIVIL CASE NO. _____
JUDICIAL DECLARATION
OF NULLITY OF MARRIAGE
ANGELO KIM
Respondent.
x—————————————————————x
AFFIDAVIT
THE PARTIES
1. Petitioner, Natasha S. Quinto (Natasha for brevity) is likewise of legal age, Filipino and is last known by
the Petitioner to be residing at Block-16, Lot-3, Kalayaan Village, Pasay City.
Respondent, Angelo A. Kim (Kim for brevity) is of legal age, Filipino and presently residing at Blk-26,
Lot-4, Kalayaan Village, Pasay City; where he may be served by notices, orders and processes of the
Honorable Court
PLAINTIFF, through counsel, alleges:
2. That on February 3, 1975, in the City of Manila, Philippines, defendant Angelo A. Kim alias Ang Kim,
being then connected with the American Armed Forces and introducing himself by the name of Okamoto,
forced plaintiff, who was then only 17 years of age, to enter into a contract of marriage with him,
employing threats and intimidation of bodily harm.
3. That defendant, also by means of force, threats and intimidation of bodily harm, forced plaintiff’s mother
C.D., to sign her conformity to the marriage;
4. That, as consequence of the threats of bodily harm, and intimidation, a contract of marriage between
plaintiff and defendant was executed and signed on February 3, 1975, before the Aglipayan Bishop, E. F.,
at the Malate Church, Manila;
5. That, in the Marriage Contract, defendant signed his name as Ang Kim, and misrepresented himself as
Filipino citizen, falsely making it appear therein that his father is one Enrique Kim, Filipino, and his mother
one Feliza Arenas, Filipina.
2. 6. That, the only factor which motivated plaintiff to enter into said marriage contact was the threats of bodily
harm and intimidation made her and to her mother by defendant;
7. That, immediately after the celebration of said marriage, defendant left for an unknown destination, there
was no cohabitation at all between him and plaintiff.
WHEREFORE, it is respectfully prayed that judgment issue:
1. Declaring null and void the marriage contract entered into by and between plaintiff and defendant on
February 3, 1975, before the Aglipayan Bishop, E. F.
2. Other reliefs just and equitable are prayed for.
June 27, 2013
Pasay City
IN WITNESS WHEREOF, I have set hereunto my hand this ______________________, 2013,
____________________.
NATASHA S. QUINTO
Affiant
SUBSCRIBED and sworn to before me, in the city/municipality of Pasay, this _________ day of __________ 2013
Doc.No.; _____
Page No.; _____
Book No.; _____
Series of 2009.
P, C and Associates Law Offices
Counsel for Petitioner